The British parliament is set to finally approve a divisive law this week to deport asylum seekers to Rwanda, but further legal hurdles could yet hold up or derail one of Prime Minister Rishi Sunak’s key policies.

The “Safety of Rwanda” bill aims to cut immigration by deterring migrants from arriving without permission, but refugee rights groups say it criminalises genuine asylum seekers, and Britain’s Supreme Court ruled last year that the East African nation was not a safe country to send people.

Sunak has invested huge political capital in the Rwanda scheme, promising that it will stop tens of thousands of people arriving without permission in small boats across the Channel.

The new legislation is expected to get lawmakers’ approval by the end of the week, but whether the Rwanda scheme does finally get off the ground remains far from certain.

Charities and human rights groups say they are gearing up to bring challenges on behalf of individuals, although as yet none have been specifically told they would be sent to Rwanda.

Here are some countries that have taken a similar approach to migration, or are considering it:

Australia

Introduced in 2001, Australia's offshoring asylum programme specifically targets migrants arriving in Australian waters by boat and is aimed at discouraging refugees from making dangerous ocean crossings and stopping people smuggling.

Asylum seekers have been transferred to offshore detention centres in Papua New Guinea's Manus Island and the South Pacific island nation of Nauru for their claims to be processed.

The policy – known as the “Pacific Solution” – was dismantled in 2008, but it was revived in 2012 and became more restrictive in 2013, when the government said people arriving by boat would be denied resettlement, even if recognised as refugees.

Since 2012, more than 4,000 asylum seekers, including children, have been sent to detention centres in Manus and Nauru for processing. Many have waited more than five years for their asylum claims to be processed, according to the Refugee Council of Australia, a non-governmental organisation.

The offshoring asylum policy has been strongly criticised by the United Nations and aid groups that cite harsh conditions in the centres including abuse by guards and self-harm and depression among detainees.

Australia closed the facility on Manus Island in 2021 after Papua New Guinea's Supreme Court ruled it was illegal.

As of October 31, 2023, about 15 people were being processed in Nauru, according to official figures.

Israel

In 2014, Israel introduced a now-defunct policy to send those rejected for asylum and illegal immigrants – mainly from Sudan and Eritrea – to Rwanda and Uganda for third-country resettlement.

They were given the choice of either being deported to their country of origin or accepting a payment of $3,500 and a plane ticket to either Uganda or Rwanda, with any who stayed in Israel facing jail.

Israel has said about 20,000 people either returned home or went to one of the East African countries under the policy, which human rights groups criticised for sending refugees to countries where there were no guarantees for their safety.

The Israeli programme was scrapped in 2019 following its suspension by the country’s Supreme Court.

European Union

As it strives to deter the flow of seaborne migrants to its shores, Italy moved a step closer to becoming the first EU country to have a non-EU country process migrants on its behalf.

Albanian lawmakers voted in February to ratify a deal with Rome to host up to 36,000 migrants per year in two purpose-built centres in the country.

The centres, one on the coast for identification and another inland for detention, would be paid in full by Italy and operate under its jurisdiction, meaning they would be covered by European Union asylum rules.

Prime Minister Giorgia Meloni said the facilities should be operational in spring 2024, but the European Commission has not yet said whether the initiative is in line with EU law.

Along with Austria, Germany has also expressed interest in the possibility of processing asylum seekers abroad.

Denmark, which has introduced increasingly strict immigration policies over the last decade, passed a law in 2021 allowing refugees to be moved to asylum centres in a third country for processing. It was in talks with Rwanda about cooperation on migrants, but has since put the plans on hold.

The EU indirectly supports offshore asylum programmes as part of broader efforts to stop refugees coming across the Mediterranean.

The bloc has paid Turkey billions of dollars to keep refugees from reaching Greece and has funded the Libyan Coast Guard, which pushes migrant boats bound for Europe back to North Africa. It is also helping to fund UN-run centres in Niger and Rwanda to process asylum seekers.

Under a UN programme called the Emergency Transit Mechanism, more than 3,000 people from Libyan detention centres, who were heading for Europe, have been transferred to Niger.

A similar scheme sending asylum seekers from Libya to Rwanda began in 2019.

The United Nations says the arrangement is reasonable because it protects migrants from possible torture, sexual violence and indefinite detention in Libya.

This article first appeared on Context, powered by the Thomson Reuters Foundation.